Commitment to Lawful, Ethical & Transparent Trading

Black Falcon Petroleum FZ-LLC is fully committed to conducting its business in strict compliance with all applicable laws, regulations, and international standards governing energy and commodities trading.

Our Compliance & Anti-Money Laundering (AML) Policy reflects a zero-tolerance approach to:

• Money laundering

• Terrorist financing

• Sanctions violations

• Fraud, corruption, or unethical conduct

This policy applies to all employees, directors, counterparties, agents, and intermediaries acting on behalf of the Company.

Regulatory & Legal Framework

Our compliance program is aligned with:

• UAE Federal Decree-Law No. 20 of 2018 (AML/CFT)

• UAE Cabinet Decision No. 10 of 2019

• FATF Recommendations

• UN, OFAC, EU, and UK sanctions regimes

International banking compliance standards

We operate under the oversight of RAKEZ and relevant UAE authorities.

Risk-Based Compliance Approach

Black Falcon Petroleum employs a Risk-Based Approach (RBA) across all business activities.

Risk assessments consider:

• Jurisdiction

• Counterparty profile

• Commodity type

• Transaction structure

• Payment mechanisms

• Logistics routes

Transactions assessed as unacceptable risk are declined regardless of commercial merit.

Customer Due Diligence (CDD)

Know Your Customer / Business (KYC/KYB)

All clients and counterparties undergo mandatory due diligence prior to engagement.

This includes:

• Legal existence verification

• Ownership and UBO identification

• Source of funds and economic purpose assessment

• Sanctions and PEP screening

• Adverse media review

Enhanced Due Diligence (EDD)

EDD is applied where heightened risk exists, including:

• High-risk jurisdictions

• Politically Exposed Persons (PEPs)

• Complex ownership structures

• Unusual transaction patterns

EDD may involve senior management approval and additional documentatio

Ongoing Monitoring Compliance does not end at onboarding.

We continuously monitor:

• Transaction behavior

• Payment flows

• Changes in ownership or control

• Sanctions and regulatory updates

Any suspicious activity is escalated and, where required, reported to competent authorities.

Commitment to Lawful, Ethical & Transparent Trading

Regulatory & Legal Framework

Our compliance program is aligned with:

International banking compliance standards

Risk-Based Compliance Approach

Risk assessments consider:

Customer Due Diligence (CDD)

This includes:

Enhanced Due Diligence (EDD)

EDD is applied where heightened risk exists, including:

Ongoing Monitoring Compliance does not end at onboarding.

Sanctions Compliance

We do not engage in:

Anti-Bribery & Anti-Corruption

We prohibit:

Our policy aligns with:

Record Keeping & Audit Trail

We maintain comprehensive records of:

Training & Awareness

All relevant personnel receive:

Reporting & Whistleblowing

We maintain secure channels for:

Enforcement & Disciplinary Measures

Public Assurance Statement

Commitment to Lawful, Ethical & Transparent Trading

Regulatory & Legal Framework

Our compliance program is aligned with:

International banking compliance standards

Risk-Based Compliance Approach

Risk assessments consider:

Customer Due Diligence (CDD)

This includes:

Enhanced Due Diligence (EDD)

EDD is applied where heightened risk exists, including:

Ongoing Monitoring Compliance does not end at onboarding.

Sanctions Compliance

We do not engage in:

Anti-Bribery & Anti-Corruption

We prohibit:

Our policy aligns with:

Record Keeping & Audit Trail

We maintain comprehensive records of:

Training & Awareness

All relevant personnel receive:

Reporting & Whistleblowing

We maintain secure channels for:

Enforcement & Disciplinary Measures

Public Assurance Statement

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